Topsfield MA Bicycle Motor Vehicle Accident
Feniger & Uliasz Lawyers
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COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS. NEWBURYPORT DISTRICT COURT
v. COMPLAINT AND REQUEST
FOR JURY TRIAL
1. The Plaintiff is and at all times herein mentioned was a resident of Town of Newbury, County of Essex, Commonwealth of Massachusetts.
2. The Defendant is and at all times herein mentioned was a resident of Town of Beverly, County of Essex, Commonwealth of Massachusetts.
3. Plaintiff was operating his bicycle with due care and caution in an easterly direction on Route 97 in Topsfield, Massachusetts when he collided with a vehicle operated by Defendant who was traveling in a westerly direction on Route 97.
4. As a direct and proximate result of the accident the Plaintiff suffers from serious and permanent injuries including right adductor strain, post-traumatic vertebral subluxation complex to the cervical and thoracic spine and hematoma of the right leg.
5. As a direct and proximate result of the alleged incident the Plaintiff has been caused to incur Four Thousand Nine Hundred Eighteen Dollars and 10/100 ($4,918.10) in medical bills to date.
6. As a direct and proximate result of the alleged incident the Plaintiff has been caused to lose One Thousand Eight Hundred Thirty-Seven Dollars and 50/100 ($1,837.50) in wages.
7. As a direct and proximate result of the alleged accident the Plaintiff has experienced conscious pain and suffering and continues to experience conscious pain and suffering.
8. The Defendant owed a duty to the Plaintiff to operate his vehicle in a safe and reasonable manner.
9. The Defendant breached his duty by failing to yield and executing a left turn into the path of the plaintiff, failing to keep his motor vehicle under proper control, failing to keep a proper lookout for bicyclists, and operating his motor vehicle without due caution under the circumstances causing a collision with the bicycle operated by the Plaintiff.
10. The Plaintiff in no way contributed to his injuries.
WHEREFORE, Plaintiff requests:
1. Judgment for damages plus interest from the day of his cause of action.
2. Reasonable cost and attorney’s fees.
3. For such other and further relief as this Honorable court may deem just and proper.
The Plaintiff demands a jury to hear his cause.